Conformity Assessment And Risk Management Under .

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Conformity Assessment and Risk Managementunder Consideration of Applicable HarmonizedStandardsDipl.-Ing. Sven Wittorf, M.Sc.Lübeck, 2013-09-12

Declaration of Conformity

Conformity Assessment ProceduresAnnex VIIAnnex IIIAnnex IIECdeclaration ofconformityEC type-examinationfull qualityassurancesystemAnnex IVAnnex VAnnex ualityassurancexxxx

Manufacture DesignConformity Assessment ProceduresAnnex VIIAnnex IIIAnnex IIECdeclaration ofconformityEC type-examinationfull qualityassurancesystemAnnex IVAnnex VAnnex ualityassurancexxxx

Conformity Assessment ProceduresAnnex VIIAnnex IIIAnnex IIECdeclaration ofconformityEC type-examinationfull qualityassurancesystemAnnex IVAnnex VAnnex VIECverificationnot ynot reassurancecommendedxxxxAccording to NB-MED/2.2/Rec4

Conformity Assessment ProceduresAnnex VIIAnnex IIIAnnex IIECdeclaration ofconformityEC type-examinationfull qualityassurancesystemHardlyAnnex IV applicableAnnex V Annex softwareassuranceassurancexxxx

Conformity Assessment ProceduresAnnex IIECdeclaration ofconformityEC type-examinationfull qualityassurancesystemAnnex IVAnnex VAnnex ualityassurancexxxxall the rest Annex IIIClass IAnnex VII

Annex IX – Classification of SoftwareStand alone software is considered to bean active medical device.MDD Annex IX – Definition 1.4

Annex IX – Classification of SoftwareActive devices intended for diagnosis are inClass IIa [ ] if they are intended to allow directdiagnosis or monitoring of vital physiologicalprocesses [ ]MDD Annex IX – Rule 10

Annex IX – Classification of SoftwareActive devices [ ] specifically intended formonitoring of vital physiological parameters,where the nature of variations is such that itcould result in immediate danger to the patient[ ], are in Class IIbMDD Annex IX – Rule 10

Annex IX – Classification of SoftwareAll other active devices are in Class I.MDD Annex IX – Rule 12

Annex IX – Classification of SoftwarenoOther rules apply(e.g. rule 9)?Class accordingto other rule(s)yesyesdirect diagnosis ormonitoring of vitalphysiological processes?variations of parameterscould result in immediatedanger?yesClass IClass IIaClass IIb

Guideline on ClassificationMEDDEV 2.1/6 – Classification of Standalone Software

Essential RequirementsThe devices must meet the essentialrequirements set out in Annex I whichapply to them, taking account of theintended purpose of the devicesconcerned.MDD Article 3 – Essential requirements

Essential RequirementsThe devices must be designed andmanufactured in such a way that [ ] theywill not compromise [ ] the safety ofpatients [ ]MDD Annex I – Essential Requirement #1

What is „Safety“?Safety:freedom from unacceptable riskISO/IEC Guide 51:1999, definition 3.1, cited in ISO 14971:2012

Essential RequirementsRequirementsTestsThe devices must achieve theperformances intended by themanufacturer [ ]MDD Annex I – Essential Requirement #3

Essential RequirementsFor devices which [.] are medical softwarein themselves, the software must bevalidated according to the state of the arttaking into account the principles ofdevelopment lifecycle, risk management,[ ].MDD Annex I – Essential Requirement #12.1a

Essential RequirementsRequirementsTestsFor devices which [.] are medical softwarein themselves, the software must bevalidated according to the stateof the artIntegrationArchitectureTeststaking into account the principlesofdevelopment lifecycle, risk management,[ ].Module TestsDesignImplementationMDD Annex I – Essential Requirement #12.1a

Long long before Konrad Zuse

Risk Management1 Identify risks2 Estimate and assessrisks3 Control risks

Quality Management1 Plan things2 Do things3 Check if things have beendone according to the plan

Medical Software?

Harmonized StandardsMember States shall presumecompliance with the essentialrequirements [.] in respect of deviceswhich are in conformity with [.]harmonized standards [.]MDD Article 5 – Reference to standards

Harmonized Standard

Harmonized (Process) StandardsMedical Device Directive 93/42/EECrequiresrequiresrequiresrequiresSW sabilityEN ISO 14971EN 62366requiresrequiresEN 62304EN ISO 13485requiresrequires

Technical DocumentationThe technical documentation must allowassessment of the conformity of the productwith the requirements of the Directive.MDD Annex VII – EC Declaration of Conformity

Technical Documentation39

RecommendationNB-MED/2.5.1/Rec5 – Technical Documentation

Summary: Medical Software

Any questions?sven.wittorf@johner-institut.de43

According to NB-MED/2.2/Rec4. Conformity Assessment Procedures Annex III EC type-examination Annex IV EC verification Annex V production quality assurance Annex VI product quality assurance Annex VII EC declaration of conformity Annex II full quality assurance system xxxx Hardly

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